Anders v. Commissioner
United States Tax Court
Petitioners obtained a 5-year option to purchase an entire tract of land. After 4 1/2 years petitioners received an offer to purchase a part of the tract and a check for $ 5,000 from the offerors. Petitioners discussed the matter with their accountant, returned the check to the offerors, and sold the option to the accountant. The accountant exercised the option, then sold the part of the tract to the offerors.
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Petitioners obtained a 5-year option to purchase an entire tract of land. After 4 1/2 years petitioners received an offer to purchase a part of the tract and a check for $ 5,000 from the offerors. Petitioners discussed the matter with their accountant, returned the check to the offerors, and sold the option to the accountant. The accountant exercised the option, then sold the part of the tract to the offerors. The accountant continued to sell various parcels of the tract thereafter, paying the purchase price of the option from the proceeds of the sales. Held: Petitioners sold the option to…
1Opinion of the Court
Drennen, Judge:
In these consolidated cases respondent sought deficiencies in Federal income tax and additions to tax as follows:
Docket No. Petitioner Year Deficiency Addition to tax under sec. 6653(a), I.R.C. 19541
8932-73 Claude Anders and Joyce Anders., 1968 $13,824.55 $691.23
8933-73 Wade H. Patrick and Ethel H. Patrick. 1968 25,427.93 1,271.37
1969 26,822.12 1,841.11
In docket No. 8933-73, respondent filed an amendment to his answer seeking an increase in the deficiency for 1969 from $21,289.81 to $26,822.12 and an increase in the addition to tax for 1969 from $1,064.49 to $1,341.11. After…
2Cases cited7 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
- Estate of Mason v. CommissionerUnited States Tax Court · 1975
- Max H. Barber v. United States of America, William L. Taylor v. United StatesCourt of Appeals for the Eighth Circuit · 1954
- Blick v. CommissionerUnited States Tax Court · 1958
2 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Lane v. CommissionerUnited States Tax Court · 1986
- Adams v. CommissionerUnited States Tax Court · 1997
- Al-Hakim v. CommissionerUnited States Tax Court · 1987
- Anders v. CommissionerUnited States Tax Court · 1977
- Baker v. CommissionerUnited States Tax Court · 1994
2 more not listed; retrieve them via the Exa API.